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Blog: Kamila DOBOSZ

10 March 2022
Kamila DOBOSZ

In 2021, among the taxpayer’s reporting and information obligations for the tax year ending on December 31, 2020, there were reporting on contracts concluded with non-residents within the meaning of the foreign exchange law (ORD-U form) and reporting related to transactions with related entities or contractors from tax havens (TPR form). The obligation to submit the ORD-U information expired on March 31, 2021, and the TPR information on December 31, 2021.

7 May 2021
Kamila DOBOSZ

Changes concerning transfer pricing in transactions with tax havens, effective as of 1 January 2021, will be challenging for taxpayers. Under the new regulations, there is an obligation to have verify whether transactions where the beneficial owner has its place of residence, registered office or management in a tax haven comply with the arm’s length principle (and it is unclear whether the legislator means the actual owner of our contractor or the cash flow generated as a result of a given transaction, as the regulations fail to specify this). What is more, taxpayers must provide economic justification for their transactions with tax havens.

28 July 2020
Kamila DOBOSZ

Today, we will once again discuss the most interesting advance tax rulings in individual cases that have been published recently. We hope it will give you some insight into transfer pricing and make it easier for you to prepare your 2019 tax documents. The advance tax rulings that will be analysed here apply to the legislation in force as of 1 January 2019. We will briefly discuss tax rulings on: partnerships, exemptions from the documentation obligation as regards a loss from a revenue stream including the controlled transaction, and the documentation obligation for a cash contribution.

7 April 2020
Kamila DOBOSZ

The current pandemic has a significant impact on transactions between affiliated entities. Deadlines for taxpayers’ obligations related to submitting declarations of the local file preparation and information on transfer prices remain effective, i.e. they fall on 30 September 2020. Under Art. 31z of the so-called special act the time limit has been extended until 30 September 2020 for entities beginning their fiscal year after 31 December 2018 and finishing before 31 December 2019.

3 March 2020
Kamila DOBOSZ

When preparing 2018 tax documentation, most related entities opted for the 2019 tax regime in order to benefit from the exemption from the reporting obligation for domestic transactions. Pursuant to Article 11n of the CIT Act (Corporate Income Tax Act), related entities having their place of residence, registered office or management board on the territory of the Republic of Poland can be exempt from the obligation to prepare a local file in transfer pricing.

22 May 2019
Kamila DOBOSZ

In this post, we are going to discuss the recommendations of Working Group no.3, which addressed re-invoicing and the hierarchy of transfer pricing methods. These recommendations have been prepared for transfer pricing regulations that have been in force since 1 January 2019.

16 April 2019
Kamila DOBOSZ

Pursuant to the Regulation of 27 April 2018, the Ministry of Finance (hereinafter: MF) established the Transfer Pricing Forum (TPF) to respond to taxpayers’ needs concerning the clarification of different aspects of transfer pricing. The forum is a team comprising people who are professionally involved in transfer pricing, both as regards theory and practice, as well as the MF and the National Revenue Administration representatives.

8 March 2019
Kamila DOBOSZ

The turn of 2018 and 2019 is the time of publishing new regulations on transfer pricing. These regulations are included in Chapter 1a of the CIT Act and Chapter 4b of the PIT Act. On 29 and 31 December 2018, regulations of the Minister of Finance were published in the Journal of Laws, being secondary legislation to transfer pricing provisions.

19 February 2019
Kamila DOBOSZ

In 2019, taxpayers can choose the provisions according to which they will prepare tax documentation for the year 2018 that has just ended themselves. According to the amended provisions of the CIT Act and the PIT Act, taxpayers can apply provisions that are formally in force as of 1 January 2019 to group transactions concluded already in 2018. Preparing tax documentation according to the new regulations may make things easier for the taxpayer; yet, it may also generate new problems and obligations the taxpayer would not have to face, had they used the earlier regulations.

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